When did the Bank have standing to sue Petitioner/D.T. to remove a claimed uncertainty?

Questions Presented for Review. Introductory Statement: Like most states, Texas adopted the Uniform Declaratory Judgment Act. As did other states, until now the Supreme Court of Texas consistently ruled that the Act confers no jurisdiction on the courts; instead, jurisdiction must be established independent of the Act. In this case, the Court of Appeals of Texas for the Fifth District was the highest court that entered an opinion and judgment. That court decided that Tex. Civ. Prac. & Rem. Code § 37.004 of the Act conferred jurisdiction on the trial court to make the declaration sought by Respondent Bank to remove a claimed uncertainty. Further, the Court of Appeals decided that Bank’s admission of fact in its Motion for Summary Judgment that it “filed this action to protect its customer...” did not moot Bank’s standing, an element of subject matter jurisdiction. As a result, Petitioner expended more than $15,000.00 in attorney’s fees — for which a counterclaim was filed — that were not awarded to Petitioner, because she was not the prevailing party. Question 1: When its petition was filed, did the Bank have standing to sue Petitioner/D.T. to remove a claimed uncertainty? Question 2: After the Bank pled in its Motion for Summary Judgment that it “filed this action to protect its customer...”, did the Bank’s standing — if any — to sue Petitioner/D.T. for declaratory judgment become moot? Question 3: Did Petitioner/D.T. have a 14th Amendment right to Equal Protection of the laws governing standing of a plaintiff to file a lawsuit and to perpetuate a lawsuit to judgment against her? If so, was Petitioner’s/D.T.’s right violated? i